Seven Steps for Children’s Advocates Reviewing Essential Health Benefit Benchmarks

HHS recently posted the proposed 2017 Essential Health Benefit (EHB) benchmark benefit plans (BBP) and supporting documents for the 50 states and DC. Though the 30-day public comment period is short, it provides an important opportunity for state advocates and stakeholders to review their state’s EHB BBP and raise any concerns before final federal approval.

The EHB requirements are intended to ensure that all private health insurance plans have robust coverage. As Say Ahhh! readers know, we are concerned about whether private health insurance options for children and families are comparable to other forms of coverage such as the Children’s Health Insurance Program (CHIP). But the proposed 2017 EHB BBP provides an opportunity to ensure that private coverage options meet the Affordable Care Act’s requirements for comprehensive coverage.

If you’re like me, the task of reviewing each of these benefits to make sure they deliver on the promises of the ACA in such a short time is totally overwhelming. But fear not! Michelle Lilienfeld at the National Health Law Program prepared an EHB overview to get your head back in the game and a handy step-by-step guide to make the benchmark analysis much easier. It is unlikely that the federal review process will result in a different EHB BBP selection, so it is best to focus on whether the selection complies with the law and is as strong as possible for children and families. Here are the steps:

  1. Find your state’s proposed 2017 EHB BBP
  2. Review the additional materials, including the benchmark benefits chart and the supporting benefits document
  3. Ensure the 10 EHB statutory benefit categories are covered
  4. Ensure benefit categories are supplemented correctly
  5. If your state has made plan documents on all of the possible EHB BBP options, compare the selected EHB BBP to the other options and identify the best choice for your state
  6. Review your state’s EHB BBP prescription drug coverage
  7. Raise any concerns regarding discriminatory benefit design

As you review the EHB BBP, there are a couple of additional items to keep in mind with respect to coverage for children and families. Asking the questions below can help you focus on their unique needs:

Are pediatric vision and dental benefits included in the EHB BBP? If not, are they accounted for via supplementation? EHB BBP selections that do not include pediatric vision and dental services must be supplemented with either the Federal Employees Dental and Vision Program (FEDVIP) or the benefits available under the state’s separate CHIP plan.

Does the EHB BBP comply with the new uniform definition of habilitative services? 

Does the EHB BBP cover children up to age 19?

Are any benefits limited based on age, raising questions about discriminatory benefit design?

The 30-day public comment period ends on September 30, 2015, so the time is now to review your state’s submission and raise any concerns!